ML20034H073
| ML20034H073 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 03/04/1993 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | CALIFORNIA, STATE OF |
| References | |
| CAL-2038, NUDOCS 9303150207 | |
| Download: ML20034H073 (4) | |
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l March 4,1993 CAle2038 l
i VIA OVERNIGHT EXPRESS SERVICE i
Radioactive Material Licensing Department State of California Department of Health Services 1
Radiologic Health Branch 610 North 7th Street Sacramento, CA 95814-0208
Subject:
Radioactive Materials License No. 0145-80; URGENT REOUEST SVA Deconunissioning Project Status; General Atomics' Post-decontamination 1 l
Survey; Request for State Participation in NRC Confirmatory Survey and Release of Bldg. 37 (SVA) for Purposes of Dismantlement
Dear Sirs:
As you are aware, General Atomics (GA) is in the process of decommissioning its HTGR Fuel Fabrication Facility located in the northern half of its Building 37 (also known as GA's Sorrento Valley "A" (SVA) facility). And, while there were both State of California and U.S.
Nuclear Regulatory Commission (NRC) licensed materials (i.e., thorium and highly enriched uranium) used in this facility, by mutual agreement, the NRC has the role oflead agency _for this.
i project. That being the case, this work is being conducted in accordance with a plan titled, "SVA Decommissioning Plan," which was submitted to the NRC and the State by letter dated 1
March 30,1990 (Ref.1), revised in response to NRC comments and resubmitted to the_NRC ~
and the State by letter dated August 24,1990 (Ref. 2), and approved by NRC in November 1990 (Ref 3).
Originally, the approach, as described in the plan, was to decontaminate the entire SVA '
fuel fabrication facility, cbtain its release to unrestricted use and then dismantle it. However,;
because of contamination on inaccessible surfaces such as the roof's trusses and because it is impractical to remove the contamination with the trusses in place, it was necessary to develop an alternate approach. ' After careful consideration as to how best to proceed, a two phase approach 'was formulated that is both practical and safe.for the workers, the public, and the' environment, j
Briefly,. the first ' phase. of this approach consisted of decontaminating-accessible'-
comaminated surfaces to levels which meet the guidelines for release to unrestricted use, the application of fixative on those surfaces that cannot be decontaminated, conducting.a pre =
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dismantlement radiological survey, documenting the survey results in a pre-dismantlement report, and obtaining NRC concurrence that the facility is safe to open to the environment and dismantle
. under carefully controlled conditions.
a 9303150207 930304 PDR ADOCK 07000734 C
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l ssso cENERAL MOWCS COURL SAN DIEGO.-CA 92121-1194 PO BOX 85608. SAN OtEGO. CA 02186-9784 (6191455-3000 4/f Q,. N T
c State of California, DOHS March 4,1993 CAL-2038 Page 2 The second phase consists of dismantling the facility, packaging and disposal of waste, conducting any needed site (i.e., soil) remediation, conducting a final radiological survey to.
demonstrate compliance with approved criteria for release to unrestricted use, documenting these data in a final report submitted to the NRC and State of-California, and requesting a confirmatory survey as the basis for release of the site to unrestricted use.
During dismantlement (Phase II), those portions of the facility meeting the criteria for release to unrestricted use will be disposed of at a sanitary landfill and those portions with fixed contamination will either be decontaminated or packaged for disposal at a U.S. Department of -
Energy low-level radioactive waste disposal site.
The above described two-phase approach was discussed with the NRC on May 2,1991.
A written summary description was submitted for NRC's concurrence and a copy sent to the State on May 30,1991 (Ref. 4). NRC approval was obtained by letter dated August 12,1991 (Ref.5).
Another change to the SVA Decommissioning Plan was necessitated when NRC staff confirmed that there are significant unresolved concerns regarding the technical content of NUREG/CR-5512; which was to provide the technical basis for release criteria derived from a pathway analysis. Consequently, GA requested (Ref. 6) and received (Ref. 7) NRC concurrence
.i that: 1) the NRC approved criteria for release of facilities and equipment to unrestricted use are not those stated in GA's SVA Decommissioning Plan, but rather, are those found in " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use ~or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," and 2) the applicable NRC approved release criteria for soil are those of Option 1 of the NRC Policy Issue SECY 81-576.
Phase I of the SVA Decommissioning project has now been completed. The only radio-active contaminants found were thorium and highly enriched uranium. The results of GA's pre-dismantlement radiological survey of the SVA Fuel Fabrication Facility demonstrate that the facility meets the prerequisite criteria for dismantlement (Refs.- 4 & 5). Specifically, those criteria are that the facility. surfaces (except those that require dismantlement in order to gain.
access) meet the approved guidelines for release to unrestricted use pr have readily identifiable fixed contamination, and that, therefore, it is safe to open the building to the environment and i
commence dismantling it in a carefully controlled manner. These results are documented _in the.
i enclosed report titled, "SVA Decommissioning Project Phase I (Pre-Dismantlement) Survey Report," dated February 1993.
i Accordingly, GA hereby requests that its SVA Fuel Fabrication Facility, with exceptions.
as described in the enclosed report, be released to unrestricted use for nurnoses of dismantlement.
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State of California, DOHS March 4,1993 CAL-2038 Page 3 GA has submitted copies of the enclosed report to the NRC along with a request for them l
to conduct a confirmatory survey of GA's SVA Fuel Fabrication Facility so it can be released to unrestricted use for purposes of dismantlement. The enclosed report provides necessary j
information to assist you in assessing the need for, and in planning for, any confirmatory survey l
to be conducted by the State of California. As on previous occasions, may we suggest that a confirmatory survey, if deemed appropriate, to be coordinated with the scheduling for the NRC survey so as to expedite the release in the most efficient manner. Such coordination may be arranged by contacting Messrs. Robert J. Pate or Michael Cillis of NRC's Region V office.
Further, inasmuch as the NRC is the lead agency and it has been asked to release the j
SVA Fuel Fabrication Facility for purposes of dismantlement, GA requests that the State of California grant its approval of such a release by communicating a favorable recommendation to the NRC.
That being the case, GA will commence dismantlement upon receiving l
authorization from the NRC; which will be deemed to also represent the approval of the State of California.
l If you should have any questions regarding our request or th:: enclosed report, please l
contact me at (619) 455-2823. Please note that GA is hopeful of the NRC confirmatory survey being scheduled for some time in the next few weeks; thus the urgency of our request.
l Inasmuch as the SVA Decommissioning Project is at a hold point untilit receives NRC l
approval to dismantle, your assistance in expeditiously responding to our request is very much l
appreciated.
i
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Very truly yours,
- h-Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance
]
KEA:shs i
Enclosures:
j Report titled, "SVA Decommissioning Project Phase I (Pre-Dismantlement) Survey Report" dated Febmary 1993 (2 copies) i cc:
.Ms. Elinor G. Adensam, U.S. NRC Headquarters (w/o encl.)
Mr. Robert J. Pate, NRC Region V (w/o encl.)
Mr. Kim Wong, State of California, Department of Health Services l
Radiation Health Unit (1 copy of enclosure)
l State of California, DOHS CAL-2038 March 4,1993 Page 4
References:
1.
Asmussen, K. E., Letter No. 696-1534 to Charles J. Haughney, " Submittal of SVA Decommissioning Plan," dated March 30,1990. (Copies to Dr. Gerard Wong, State of California, DOHS, Radiologic Health Branch and Mr. David Speed, State of California, i
DOHS, Environmental Management Branch) 2.
Asmussen, K. E., Letter No. 696-1612 to George H. Bidinger, " Submittal of Additional Information in Support of Request for SVA Decommissioning Plan Approval," dated August 24,1990. (Copies to Dr. Gerard Wong, State of California, DOHS, Radiologic Health Branch and Mr. David Speed, State of California, DOHS, Environmental Management Branch) i 3.
Haughney, Charles J., letter to General Atomics, ATTN: Dr. Keith E. Asmussen, License No. SNM-696 Amendment No.16, dated November 13,1990 4.
Asmussen, Keith E., Letter No. 696-1743 to George Bidinger, "SVA Decommissioning and Building Dismantlement," dated May 30,1991. (Copics to Dr. Gerard Wong, State of California, DOHS, Radiologic Health Branch, Mr. David Speed, State of California, DOHS, Environmental Management Branch, and Mr. Kim Wong, State of California, DOHS, Radiation Health Unit) 5.
Haughney, Charles J., letter to General Atomics, ATTN: Dr. Keith E. Asmussen, License No. SNM-696, dated August 12, 1991 6.
Asmussen, K. E.,' Letter No. 696-1896 to John W. N. Hickey, " Decontamination Guide-lines for GA's SVA Decommissioning Project," dated April 14,1992. (Copies to Dr.
Gerard Wong, State of California, DGHS, Radiologic Hea!th Branch and Mr. Hank Kocol, State of California, DOHS, Environmental Management Branch).
7.
Hickey, John W. N., Letter to General Atomics, ATTN: Dr. Keith E. Asmussen, License No. SNM-696, dated May 1,1992
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